Nancy Royal v. John Spragins, 575 F. App'x 300

Royal sued three Wichita Falls police officers, the City, and the Chief under § 1983 for alleged Fourth Amendment excessive force in a suicidal-subject shooting.
Officers responded to a 911 call about Jeffery Cole Royal, who exited a car holding a rifle and allegedly aimed it at officers.
Orr, nearby, stated he was within five feet and did not see Jeffery point the gun before the shooting; he saw Jeffery 'fall to the ground' after shots.
Autopsy indicated a bullet path consistent with Jeffery’s forearm extended toward the officers and the rifle directed toward them; other records corroborated officers’ statements.
Officers, detectives, and medical examiner reports, plus deposition and open-records materials, were submitted; Royal argued material factual disputes existed.
District court granted summary judgment to all defendants, finding no clearly established constitutional violation and qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officers violated the Fourth Amendment	Royal asserts genuine disputes about whether Jeffery posed a threat.	Officers claim Jeffery pointed and lowered the rifle toward them, justifying force.	There was no clear Fourth Amendment violation; the force was reasonable under the circumstances.
Whether the officers are entitled to qualified immunity	Royal contends genuine issues preclude immunity.	Officers acted reasonably; on-scene perspective supports immunity.	Qualified immunity appropriate; no violation found and no excessive force.
Whether disputed facts negate summary judgment on force reasonableness	Royal contends conflicts about timing of gun-pointing and orders.	Affidavits establish Jeffery began lowering and pointing the rifle before shooting; Orr’s account does not contradict that.	No material dispute; on-scene evidence shows reasonableness of force.
Whether municipal liability can attach absent a constitutional violation	Royal seeks city and chief liability for policy failures.	No underlying constitutional violation, so municipal liability fails.	Municipal liability denied due to absence of constitutional violation.

Ramirez v. Knoulton, 542 F.3d 124 (5th Cir. 2008) (reasonableness of deadly force when suspect poses threat)
Tennessee v. Garner, 471 U.S. 1 (U.S. 1985) (deadly force standard and danger assessment)
Graham v. Connor, 490 U.S. 386 (U.S. 1989) (objective reasonableness in use-of-force analysis)
Tolan v. Cotton, 134 S. Ct. 1861 (U.S. 2014) (on-scene perspective for excessive-force inquiries)
United States v. Nielson, 415 F.3d 1195 (10th Cir. 2005) (exigent circumstances and reasonable belief standards cited)
Elizondo v. Green, 671 F.3d 506 (5th Cir. 2012) (absence of constitutional violation precludes municipal liability)
Rios v. City of Del Rio, Tex., 444 F.3d 417 (5th Cir. 2006) (municipal liability prerequisites after constitutional violation)
Ramirez v. Knoulton, 542 F.3d 124 (5th Cir. 2008) (reaffirmation of reasonable force framework)
Burgos v. Southwest Bell Tel. Co., 20 F.3d 633 (5th Cir. 1994) (materiality of facts for summary judgment standard)